JUDGMENT :

1. The instant appeal has been preferred by the Revenue/Appellant under section 35G of the Central Excise Act against the judgment and order dated 18th December, 2019 passed by the Customs, Excise and Service Tax Appellate Tribunal, Kolkata (CESTAT) in Appeal No. E/76154/2014, whereby the appeal filed by the respondent against the common adjudication order dated 31st March, 2014 and corrigendum dated 5th May, 2014 of the Commissioner of Central Excise, Shillong, was allowed.

2. The necessary facts, in brief, are that a certain notification, being notification No. 32/99-CE, dated 8th July, 1999, had been issued by the Government of India, Ministry of Finance, wherein it was proposed to exempt goods specified in the First and Second Schedule of the Central Excise Tariff Act, 1985, from payment of Excise duty from units located in North East India, as specified in the annexure to the said notification. This scheme provided for refund of the duty of excise or additional duty of excise leviable thereon as equivalent to the amount of duty paid by the manufacturer, other than the amount of duty paid by Cenvat credit under the Cenvat Credit Rules. The respondent, which reportedly